20161117Comments.pdf

WILLIAMS · BRADBURY
A T T O R EYS AT LAW
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
4 72 W. Washington
Boise, ID 83 702
Re: PAC-E-16-12
Dear Ms. Jewell:
November 17, 2016
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Please find enclosed the original and seven copies of Comments of PacifiCorp Idaho
Industrial Customers for filing in the above referenced case.
Thank you for your assistance in this matter. Please feel free to give me a call should
you have any questions.
RLW/jr
Enclosures
Sincerely,
R~ l rJ;,t,,;._
Ronald L. Williams
1015 W. H ays Street -Boise, ID 83702
Phone: [phone] -www.williamsbradbury.com
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Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for PIIC
RE .,EIVED
70 1G:,O'./ 17 P 2=39
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER TO )
UPDATE BASE NET POWER COSTS AND )
IMPLEMENT A RA TE STABILITY PLAN )
)
________________ )
Case No. PAC-E-16-12
COMMENTS OF P ACIFICORP
IDAHO INDUSTRIAL CUSTOMERS
PacifiCorp Idaho Industrial Customers ("PIIC") appreciates the opportunity to provide
comments in this matter, and specifically to comment on the Rocky Mountain Power's proposed
Rate Stability Plan. In particular, PIIC appreciates the time and effort put forth by the
Company in this filing, and the open and transparent process initiated by the Company in
presenting the Rate Stability plan as an alternative rate proposal.
Prior to its filing in this case, the Company met with PIIC members and outlined the key
components of its compliance filing at the Commission with respect to base net power costs
(NPC), and how that filing would result in a modest 2017 rate decrease. The Company also
updated PIIC members with respect to the expected 2017 ECAM filing. Finally, the Company, in
general terms, outlined an alternative rate proposal that could apply the base NPC rate and
ECAM rate reductions as an offset to potential future rate increases.
PIIC COMMENTS Page 1
The Company's alternative rate proposal-the Rate Stability Plan-was seriously
discussed and considered at a PIIC member meeting on October 18, 2016. At that meeting, it was
decided that PIIC's preference would be for the Company to update and implement a base rate
adjustment as contemplated in Commission Order No. 33440 (Case No. PAC-E-15-19), rather
than to implement the Rate Stability Plan. That decision was communicated to the Company,
and to Staff and other Intervenors in this case, at the meeting on October 19, 2016 at the
Commission. That decision -to not implement the alternative Rate Stability Plan at this time -
remains PIIC's position in this case.
Again, PIIC wishes to express its appreciation to the Company for presenting the
alternative Rate Stability Plan to PIIC members, and the open and transparent process employed
by the Company in doing so.
Dated this 17th day ofNovember, 2016.
PIIC COMMENTS
Respectfully submitted,
R~t tJ;,a.,._
Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for PIIC
Page 2
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 17th day of November, 2016, I caused to be served
a true and correct copy of the Comments of Pacificorp Idaho Industrial Customers upon the
following individuals in the manner indicated below:
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: [e-mail]
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: [e-mail]
Randall C. Budge
Racine Olson Nye Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
E-Mail: [e-mail]
Attorney for Monsanto Company
Katie Iverson
Brubaker & Associates
17244 W. Cordova Court
Surprise, AZ 85387
E-Mail: [e-mail]
Monsanto Company
Eric L. Olson
Racine Olson Nye Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
E-Mail: [e-mail]
Attorney for Idaho Irrigation Pumpers
Association
PIIC Comments, Page 3
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Val Steiner (e-mail only)
Agrium Us Inc.,/Nu-West Industries
3010 Conda Rd
Soda Springs, ID, 83276-5301
E-mail: [e-mail]
PIIC
Jim Duke (e-mail only)
Idahoan Foods
357 Constitution Way
Idaho Falls, ID 83742
E-mail: [e-mail]
PIIC
PUC Comments, Page 4
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Ronald L. Williams